HMRC has introduced new self-assessment tax return boxes on the SA102 Employment pages for 2025/26, extending what directors report each year. Previously, a director simply confirmed they held a directorship and whether the company was close. Now HMRC wants detail about the company, shareholding and dividend position behind that directorship. These changes only apply where a director is already required to complete a tax return.
Four new disclosures are required on the Employment pages for each close company directorship, including both privately owned companies and those controlled by private equity:
A director of more than one close company needs a separate SA102 page, with the full set of boxes, for each company.
The rules do not apply to directors of registered charities or a community interest company who did not receive any employment or dividend income in the year, including any other type of distribution from that company or a connected company.
A close company is broadly a UK company controlled by five or fewer participators (broadly, shareholders and certain lenders), or by any number of participators who are also directors. Control isn't just about who holds the most ordinary shares, so it's worth testing rather than assuming.
Most owner-managed and family companies meet the test comfortably. The more common risk is a company whose control has shifted through a share issue or reorganisation, without anyone revisiting whether it is now close.
It can also get complicated where:
HMRC can charge penalties for missing information. According to recently published FAQs from the Association of Tax Technicians (ATT), HMRC has confirmed that only one £60 penalty will apply per return, however many directorships or close companies are involved.
The new boxes give HMRC a direct line between a company's share register, its dividend payments and each director's personal tax return. It might therefore make it easier for HMRC to identify any discrepancies between a company’s reporting and that of a director.
HMRC is also considering further changes to require close companies to provide additional information on transactions between the company and its participators and a consultation closed in June 2026, the results of which have not been published. This is part of modernising the reporting framework with a focus on closing the tax gap for small businesses.
If you hold several directorships or have complex structures, start early. Working out dividends and shareholding percentages takes longer than you'd expect.
These disclosures apply to the 2025/26 return, due for online filing by 31 January 2027 or 31 October 2026 for paper returns. That deadline will come round quickly. Share movements, dividend vouchers and board minutes are far easier to assemble now than to reconstruct in January.
When we prepare your personal tax return, we identify the directorships you held in the year and test each company against the close company rules, rather than relying on assumptions carried over from prior years. We then make sure the right information goes into your return.
That gives you confidence your return is right and reduces the risk of avoidable HMRC questions about your wider tax affairs.
If you're not sure which directorships are affected, we can carry out the close company analysis. For companies controlled by private equity, our specialist team can help.
For more insight and guidance, get in touch:
Natalie Iceton, Director, Private & Trusts Assurance | Private Client
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